Consumer Finance Monitor Podcast Episode: Should Congress Create a New Federal Charter for Non-Bank Payments Companies?
According to a recent press release, the issuer of the USDC stablecoin has submitted an application to the Office of the Comptroller of the Currency (OCC) to establish a national trust bank, First National Digital Currency...more
This third installment in our series of insights on bank charter considerations describes the process for seeking regulatory approval to form or acquire a bank....more
This second installment in a series of insights on bank charter considerations describes the consequences of operating through an insured depository institution charter, including capital requirements, supervision and...more
On March 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter 1183, which is expected to clarify and streamline national banks’ ability to engage in cryptocurrency activities....more
Federal Banking Agencies Issue New Guidance on Managing the LIBOR Transition - The member agencies of the Federal Financial Institutions Examination Council (“FFIEC”) have issued joint guidance for banking organizations...more
The New York Department of Financial Services (DFS) has filed its opening brief with the Second Circuit in the OCC’s appeal from the district court’s final judgment in DFS’s lawsuit challenging the OCC’s issuance of special...more
The New York State Department of Financial Services (NYDFS) has come out strongly against an Office of the Comptroller of the Currency (OCC) proposal to grant national bank charters to financial technology (fintech)...more
The Office of the Comptroller of the Currency (OCC) has proposed to allow financial technology (fintech) companies to apply for full or special purpose national bank charters. In advance of the proposal's January 15, 2017,...more
On December 2, 2016, the Office of the Comptroller of the Currency (OCC) announced its willingness to entertain applications from financial technology (fintech) companies for special purpose national bank charters. In recent...more